PRIVACY POLICY AND NOTICE

The purpose of this privacy policy (this Privacy Policy) is to explain how 6DOT50 Proprietary Limited (6DOT50), a company registered in South Africa with registration number 2015/220847/07, and/or its affiliated entities (the 6DOT50 Group) may collect, use, share, protect and otherwise handle your Personal Information (as defined below), as well as the rights you have in regard to your Personal Information. The 6DOT50 Group is concerned with and committed to protecting your privacy and confidentiality in accordance with all applicable data protection laws, including POPIA (as defined below).

By providing us with your Personal Information, either directly by using our website and/or participating in the 6DOT50 Membership Programme, or indirectly when interacting with us, you agree to this Privacy Policy and consent to us using your Personal Information as set out in this Privacy Policy. If you are under the age of 18, then you must only provide your Personal Information to us with the consent of your parent or legal guardian. If you are under 18 and provide us with your Personal Information you warrant to us that you have the requisite consent from your parent or legal guardian. We will not use your Personal Information for any purpose other than as set out in this Privacy Policy and we will do our best to protect your Personal Information that is in our possession from unauthorised use, disclosure or access.

Please note that 6DOT50 may review and update this Privacy Policy at any time. If we make any changes to this Privacy Policy, we will post the changed Privacy Policy on our website, and you are responsible for regularly reviewing the Privacy Policy to make sure that you are happy with any changes. If you are not happy with any changes, please notify 6DOT50 on info@6DOT50.com immediately. If you continue to use our website and our services, you will be deemed to have accepted the changed Privacy Policy.

We expect all Personal Information provided by or collected from you to be accurate, complete and up-to-date. Should your Personal Information change, please notify us of the change and provide us with the accurate Personal Information.

1. DEFINITIONS USED IN THIS PRIVACY POLICY

In this Privacy Policy:

6DOT50 Membership Programme” means the programme by which the 6DOT50 Group manages the exchange of value between Members and other Members and between Members and business partners of 6DOT50 using voucher products sold by the 6DOT50 Group;

6DOT50 Stakeholders” means the 6DOT50 Group and its shareholders, directors, employees, consultants, service providers, suppliers, agents and business partners;

Information Regulator” means the independent body established in terms of POPIA;

Member” means an individual or business which has registered to become of member of the 6DOT50 Membership Programme;

Personal Information” means information relating to you which can be used to personally identify you (including information such as your name, email address, mobile phone number and biometric information), either directly or indirectly and as further detailed in POPIA; and

POPIA” means the Protection of Information Act, No 4 of 2013.

2. THE PERSONAL INFORMATION WE MAY COLLECT FROM YOU AND THE PURPOSES FOR WHICH WE MAY USE SUCH PERSONAL INFORMATION

 

2.1

This Privacy Policy sets out the types of Personal Information which we may collect from you. The purpose for us collecting such Personal Information is to enable us to successfully provide you with our service, specifically providing you with a transactional services engine which allows you to store value in the form of digital money vouchers, spend that digital money and send that digital money. We primarily collect your Personal Information so that our software can uniquely identify you and link you to your 6DOT50 transactional account. We also collect your Personal Information in able to be able to communicate with you. As such, providing us with your Personal Information is essential should you wish to access our service.

2.2

The types of Personal Information which we may collect from you include the following:

(a)

YOUR NAME AND OTHER PERSONAL INFORMATION

This Personal Information may include your name, contact details, identity numbers and other such information. When you apply to be a Member, you may also be required to give us documents which may contain your Personal Information, and which comply with the applicable laws of your territory.

This information is used:

(i)
to provide you with the services and benefits that we make available to you;
(ii)
for verifying your identity for security purposes, if applicable;
(iii)
for obtaining banking information for the processing of a refund, if applicable;
(iv)
to, where applicable, allow certain persons, including but not limited to 6DOT50, to send you in-app notifications from time to time;
(v)
for marketing our services and products; and
(vi)
for loyalty programme and Business Partners to the extent applicable.

Information which does not identify you may be used in a general way by us or third parties for data analytics purposes, for example relating to demographics or usage of a particular page or service.

(b)

YOUR DOMAIN NAME, E-MAIL ADDRESS AND MOBILE NUMBER

This information is recognised by our servers and the pages that you visit and where your communications are recorded. We shall not, under any circumstances, disclose your e-mail address or mobile number to any person who is not an employee, contractor, service provider or agent of the 6DOT50 Group or any third party with whom you are not transacting through the 6DOT50 Membership Programme.

This information is used:

(i)
to correspond with you or deal with you as you expect, either directly or with suppliers with whom you are transacting
(ii)
in a collective way not referable to any particular individual, for the purpose of quality control and improvement of our service offerings;
(iii)
to send you news about the services to which you have signed up;
(iv)
to tell you about our other services or services of members and affiliated parties.
(c)

MOBILE DEVICE ACCESS

To use our mobile application, we may request access or permission to certain features from your mobile device, including your mobile device’s authentication information, phone book, camera and phone storage.

This information is used:

(i)
to enable certain features within the Application, including, but not limited to, scanning of QR Codes where applicable;
(ii)
to identify you for security authentication purposes;
(iii)
to enable you to SEND Digital Money to other 6DOT50 Members
(d)

MOBILE DEVICE DATA

When using our application, we may collect and store device information such as your device model and manufacturer, version of your operating system, phone number, country and any other data you choose to provide.

This information is use to enable certain features and benefits within the Application and to identify you for security authentication purposes.

(e)

INFORMATION YOU POST ON OR THROUGH OUR PLATFORM

Information you send to us by posting to a forum or communicating within our platforms is stored on our servers. We do not specifically use that information except to allow it to be read by intended recipients or, in the case of marketing material to visitors of our sites.

(f)

PLATFORM USAGE INFORMATION

We may use software embedded in our platform to collect information about how we perform in providing content to you and communications with members of the platform.

(g)

FINANCIAL INFORMATION RELATING TO YOUR ACTIVITIES AND TRANSACTIONS

This information may be transferred to reputable payment service providers. Their systems may be dressed in our “livery”, but it is not controlled by us. Our employees may have limited access to it.

We take the following measures to protect your financial information:

(i)
We keep your financial information encrypted on our servers;
(ii)
After processing a transaction, we delete all your financial information that is not necessary to be stored in order for you to access our services. This is to prevent the possibility of our duplicating a transaction without a new instruction from you;
(iii)
Access to your information is restricted to authorised employees only; and
(iv)
We automatically delete your information, subject to complying with retention time frames imposed by applicable laws, after your membership of the 6DOT50 Membership Programme terminates.
(h)

CALLING OUR HELP LINE

When you call our help line, we collect Calling Line Identification (CLI) information and record all calls. We use this information to help improve the efficiency and effectiveness of our help line.

(i)

SENDING A MESSAGE TO OUR SUPPORT SYSTEM

When you send a message, we collect the data you have given to us in that message in order to obtain confirmation that you are entitled to receive the information and to provide to you the information you need. We record your request and our reply in order to increase the efficiency of our business / organisation.

(j)

COMPLAINTS

When we receive a complaint from you, we record all the information you have given to us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact a third party, we may decide to give to that third party some of the information contained in your complaint.

We may also compile statistics showing information obtained from Members’ complaints to assess the level of service we provide but will do so in a way which will not identify you or any other person.

2.3

We may disclose your Personal Information to 6DOT50’s Stakeholders for legitimate business purposes and in accordance with all data protection laws. In addition, we may disclose your Personal Information:

(a)

if required by law or upon the request of legal and/or regulatory authorities or for the purposes of reporting any actual or threatened breach of applicable law or regulation;

(b)

where it is necessary for the purposes of actual or threatened legal proceedings; and/or

(c)

to any relevant third party for the purposes of the prevention, investigation, or prosecution of a criminal offence.

 

3. SECURING YOUR PERSONAL INFORMATION

We have implemented appropriate technical and organisational security measures to protect your Personal Information that is in our possession against accidental or unlawful access, disclosure, loss or destruction, in accordance with POPIA. However, you acknowledge that we cannot be held liable for any loss of privacy occurring during the transmission of your Personal Information via the internet, which is an open system and cannot be completely secured.

4. DATA RETENTION

We will only retain your Personal Information for so long as is necessary for the fulfilment of the purposes set out in this Privacy Policy or for the period required by law, whichever is longer. When we are no longer required to retain your Personal Information, it is destroyed to the extent that it can no longer be reconstructed in intelligible form and you are de-identified.

5. YOUR LEGAL RIGHTS

 

5.1

You have the right to access the Personal Information we collect from you and to ask us to rectify, erase and restrict the use of your Personal Information. If you wish to contact us in regard to your Personal Information, you may contact us at info@6dot50.com. To better safeguard your Personal Information, we will take reasonable steps to verify your identity before granting access or making corrections to your Personal Information.

5.2

You also have the right to object to how your Personal Information is being used by contacting us on info@6dot50.com or the Information Regulator on inforeg@justice.gov.za.

 

6. ADVERTISING BY THIRD PARTIES

 

6.1

Third parties may advertise through our platform (Third Party Advertisers). In doing so, such third parties, their agents or other companies working for them may use technology that automatically collects your IP address when they send an advertisement that appears on our site to your browser. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these third parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

6.2

6DOT50 shall not be liable, in any way whatsoever, for any damage, loss, liability, cost or expense, whether direct, indirect or of a consequential nature, which you may suffer as a result of or in connection with any act or omission of such Third Party Advertisers.

 

7. CONTENT YOU PROVIDE TO US WITH A VIEW TO BE USED BY THIRD PARTY

If you provide Personal Information to us with a view to it being read, copied, downloaded or used by other people, we accept no responsibility for what such other people may do with it. 6DOT50 shall not be liable, in any way whatsoever, for any damage, loss, liability, cost or expense, whether direct, indirect or of a consequential nature, which you may suffer as a result of or in connection with any act or omission of such other person.

8. COOKIES

 

8.1

Cookies are small text files that are placed on your computer’s hard drive through your web browser when you visit any website. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

8.2

Like all other users of cookies, we may request the return of information from your computer when your browser requests a web page from our server. Cookies enable our web server to identify you to us, and to track your actions and the pages you visit while you use our website. The cookies we use may last for a single visit to our site (they are deleted from your computer when you close your browser) or may remain on your computer until you delete them or until a defined period of time has passed.

8.3

Although your browser software enables you to disable cookies, we recommend that you allow the use of cookies in order to take advantage of the features of our website that rely on their use. If you prevent their use, you will not be able to use all the functionality of our website. Here are the ways we use cookies:

(a)

to process your Personal Information for the purposes set out in this Privacy Policy;

(b)

to record whether you have accepted the use of cookies on our website. This is solely to comply with the law. If you have chosen not to accept cookies, we will not use cookies for your visit, but unfortunately, our site will not work well for you;

(c)

to allow essential parts of our website to operate for you;

(d)

to operate our content management system;

(e)

to operate the online notification form – the form that you use to contact us for any reason. This cookie is set on your arrival at our website and deleted when you close your browser;

(f)

to enhance security on our contact form. It is set for use only through the contact form. This cookie is deleted when you close your browser;

(g)

to collect information about how visitors use our site. We use the information to improve your experience of our site and enable us to increase sales. This cookie collects information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they visited;

(h)

to record that a user has viewed a webcast. It collects information in an anonymous form. This cookie expires when you close your browser;

(i)

to record your activity during a web cast. An example is as to whether you have asked a question or provided an opinion by ticking a box. This information is retained so that we can serve your information to you when you return to the site. This cookie will record an anonymous ID for each user, but it will not use the information for any other purpose. This cookie will last for [three] months, when it will delete automatically;

(j)

to store your Personal Information so that you do not have to provide it afresh when you visit the site next time. This cookie will last for 90 days; and

(k)

to enable you to watch videos we have placed on YouTube. YouTube will not store personally identifiable cookie information when you use YouTube’s privacy-enhanced mode.

 

9. RE-MARKETING AND DIRECT MARKETING

 

9.1

9.1 We may use re-marketing from time to time. This involves Google or some other supplier placing a tag or marker on your website in order to be able to serve to you an advert for our products / services when you visit some other website.

9.2

9.2 We may process your Personal Information for the purposes of providing you with information regarding services that may be of interest to you. In this regard, we may contact you using your Personal Information with marketing information or with targeted advertising or use your Personal Information to tailor marketing to improve its relevance to you, unless you object. You may opt-out of these marketing initiatives at any time by contacting us on info@6DOT50.com.

 

10. INTERNATIONAL TRANSFER OF YOUR PERSONAL INFORMATION

We may transfer your Personal Information to recipients outside of the Republic of South Africa. In terms of POPIA, we are entitled to do this, provided that the foreign country to which your Personal Information is transferred has adopted adequate data protection laws which provide for a similar level of protection of your Personal Information as set out in POPIA, the recipient to whom we transfer your Personal Information undertakes to protect your Personal Information in accordance with such data protection laws and the transfer of your Personal Information is necessary in terms of fulfilling the purposes set out in this Privacy Policy.

11. GOVERNING LAW AND JURISDICTION

This Privacy Policy and/or any dispute arising from or in connection with this Privacy Policy will be governed and interpreted in accordance with the laws of the Republic of South Africa. In the event of any dispute arising between you and 6DOT50, you hereby consent to the non-exclusive jurisdiction of the High Court of the Republic of South Africa (Western Cape Division, Cape Town).

12. CONTACT US

Should you have any queries about this website or this Privacy Policy, please contact us on info@6DOT50.com.

If you are not satisfied with our response to your query or complaint or you believe that our processing of your Personal Information does not comply with POPIA or any other applicable data protection legislation, you have the right to lodge a complaint with the Information Regulator on inforeg@justice.gov.za